On
25th Jan 2007, Kim Bleimann President of Berjé Inc., made a
block-buster of a speech about the state of the aroma trade entitled “What
you’ll never hear from your boss.” His audience was the
Women in Flavour & Fragrances Commerce (WFFC)
meeting in New Jersey, and although the talk is by now 12 months old, its
message is still 100% relevant. We reproduce the speech here (with permission)
in its entirety, with a strong recommendation that everyone reads it, especially
the newcomers to this industry. It is rare to find in a speech where there is so
much contained wisdom, abject disappointment at the way the aroma industry is
being destroyed without really putting up a fight, the overall message being
tempered with some wry humour.

A
second lecture we are pleased to bring to a wider audience is that from
RobertTisserand, who bounced back on stage after a 10-year absence
from public speaking at the Alliance of International Aromatherapists
Conference in Denver, Colarado in October 2007. Robert’s paper entitled
“Challenges of Essential Oil Therapy: Proof of Safety” raises some important
issues in the safety area. Our particular interest would be to develop some of
the themes mentioned in the lecture i.e. more attention given to matrix effects
in essential oils & how the beneficial effects of individual substances
contained within natural aromatic materials, which have anti-carcinogenic,
anti-irritant, anti-inflammatory, anti-oxidative properties etc., might easily
nullify the adverse effects of other substances within the same oil/ ingredient
which are individually alleged to be irritant, carcinogenic etc. In this way we
would hope to be eventually able to show that the existing system of single
ingredient hazard-based precautionary-principled prediction attempts to
estimate the actual risks presented to the end-user for complex biological
substances, perfume compounds or finished cosmetics, is invalid.

The
subject of coumarin has made even more twists & turns in recent weeks.
Cropwatch has updated & re-issued its Coumarin – the real story document
to include the National Toxic Encephalopathy Foundation (NTEF) vs. l’Oreal’s
knock-about over alleged adverse effects from the coumarin-containing Angel
perfume by Thierry Mugler, and punches holes in the somewhat chemophobic
arguments presented by the NTEF. We separately examine the questionable Dec 2007
statement by the Federal Institute for Risk Assessment (BfR) regarding dangerous
levels of coumarin exposure from applied fragranced cosmetics, especially for
children. We conclude that the BfR may be another organisation apparently
incapable of doing a proper literature search on ingredients – had they done so,
they may not have made the statement that they did. As it is, they have been
slapped down by both the IKW and IFRA. Whilst it is rewarding to see an IFRA
spokesperson actually defending an aromatic ingredient for once (instead of
regulating us ingredient users into obscurity), we bring you aspects of the
coumarin toxicity saga that IFRA forgot to mention.

On the allergen front, a further
paper from Vocanson et al. (2007) re-addresses the lack of
allergenicity of pure coumarin, identifies a dihydrocoumarin impurity as the
possible culprit for any slight allergenicity in impure coumarin. The SCCP are
on the rack on this one - you remember that in their last Opinion they seemed to
‘misunderstand’ the results from the last paper from Vocanson & chums (Vocanson
et al. 2006). Hopefully they will understand this one, and pave the way
for a re-examination of all their previous contentious decisions on fragrance
allergens, before they are embarrassed even further by the results of even more
investigative publications.

The lack of inertia from the SCCP
regarding overdue investigations of its previous shoddy work, is revisited with
the tea tree oil (TTO) situation Almost four years on from the SCCP’s
questionable Opinion on TTO, the negativity of which caused so much damage to
confidence in the tea tree plantation business in Australia, and ten months on
from the ATTIA dutifully lodging their document to fill the TTO toxicology data
gaps that the SCCP identified, we still haven’t arrived at a revised SCCP
Opinion on TTO’s stability & safety in cosmetics. A recent Cropwatch Statement
(Jan 2008) optimistically & mistakenly identified a Brussels working group
meeting on 22nd Jan 2008 (for which TTO was on the agenda) with a final SCCP
meeting on the subject – we apologise for this. Apparently the SCCP is
overloaded with work, and ATTIA’s TTO submission is a “big document”
(nobody we know has seen it, or been able to throw it from the top of the stairs
to see how heavy it is, so we can’t possibly comment on its bigness).

So it seems that we now have an
SCCP ‘expert’ committee that isn’t actually expert; lacks necessary
cross-disciplinary skills (admitted to Cropwatch in 2007 by Brussels regulatory
staff); has previously offered Opinions when it was unable to conduct a proper
literature search (admitted to Cropwatch 2007 by Brussels regulatory staff);
makes flawed decisions which are being challenged in the scientific literature,
and now apparently can’t get through theworkload. We understand
that following a contact with a Unit C7 – Risk Assessment official, a date later
this year (perhaps June 2008?) to review a draft of the position is possible.
The need for a separate Fragrance Commission within Brussels populated by
independent fragrance experts - for which we believe there is a body of
potential support in the Brussels Parliament - was never more apparent. In this
way an admission of the relative safety of TTO might advantage the beleaguered
TTO industry, which has suffered from Brussels wrong-footedness & dithering.

To
conclude, existing EU regulatory staff continue to fail to present
sensible policies for the survival of European aroma industry as they continue,
unimpeded, to tunnel-vision their way from regulatory meeting to regulatory
meeting, to further their repressive ingredient policy agendas. Unwittingly,
perhaps, they are helping to kick the fragrance industry in the head as it lays
bleeding to death, and we desperately need a new initiative from professional,
trade & research organisations & industry itself, if natural aromatic products
are not to become completely relegated to obscurity. The clock is ticking….